Fall protection on UK construction sites is most often discussed as a subcontractor concern. The safety netting contractor is procured, the install is scheduled, the certificate is filed, and the topic drops out of the principal contractor’s active management queue. That treatment of fall protection as a subcontractor matter underestimates the principal contractor’s actual duty under CDM 2015 and under the Work at Height Regulations 2005.
The relevant duties sit clearly with the principal contractor. The Work at Height Regulations require the principal contractor to plan and organise work at height in a way that prioritises collective protection over individual protection, with falls prevented where reasonably practicable and arrested where prevention is not. CDM 2015 places the duty to coordinate health and safety matters across all contractors working on the site with the principal contractor, including the planning of fall protection in the construction phase plan.
The practical result is that the principal contractor is responsible for ensuring that fall protection is in place, appropriate to the work being performed, installed by competent personnel, inspected at the right intervals, and removed safely when no longer required. The subcontractor delivers the work. The principal contractor remains responsible for ensuring the work happens correctly.
This distinction matters most when something goes wrong. In the event of a fall, an HSE investigation will look at whether the principal contractor’s planning and coordination of fall protection was adequate. The investigation will examine the construction phase plan to see what fall protection was specified, the procurement records to see how it was specified to the subcontractor, the inspection records to see whether installation was verified, and the maintenance records to see whether ongoing condition was monitored. A weak record at any point in that chain becomes evidence that the principal contractor’s duty was not properly discharged.
The same logic applies in less dramatic situations. A near miss, a complaint from an operative about working conditions, an inspection visit from the HSE or from the principal contractor’s own client. Each of these is an occasion when the principal contractor needs to produce evidence of active management of fall protection rather than evidence of procurement of a contractor who deals with it.
Red Safety Netting structures its work with principal contractor duty in mind. Install records, inspection records, competence certifications and ongoing condition monitoring are produced in formats that drop cleanly into the principal contractor’s pre-construction file and into the live construction phase plan. The records reference the same plot numbers, dates and operatives that the principal contractor’s wider documentation uses, so the picture cross-references.
This is not a documentation theme alone. It also affects how the fall protection is designed in the first place. A safety netting contractor working in genuine partnership with the principal contractor is involved early enough in the project to influence scaffold geometry, building sequencing and trade interfaces. A safety netting contractor procured late and presented with a fait accompli geometry has to install against constraints rather than against an integrated plan.
Red Safety Netting’s preferred working pattern is integration from the construction phase plan stage. The fall protection strategy for the scheme is set with the principal contractor before subcontracts are let. The netting requirements are integrated with the scaffold design, with the roofing programme and with the building sequence. Install dates are set against the actual programme, not against a notional date used in the bid.
For developers who hold the principal contractor duties themselves, the same logic applies with more direct exposure. The developer is the party against whom HSE enforcement will be directed if planning of fall protection is found to be inadequate. The choice of fall protection contractor therefore is not just a procurement decision. It is a decision about how the developer’s own duty under CDM and the Work at Height Regulations will be discharged.
Procuring on lowest tender alone makes that discharge harder rather than easier. Procuring on demonstrable competence, documentation discipline and integration capability makes it easier. The cost difference between the two approaches is small relative to the consequence of getting it wrong. The duty does not transfer with the subcontract. It remains with the principal contractor throughout.
Talk to Red Safety Netting To discuss CDM-compliant fall protection across your scheme on your scheme, contact Red Safety Netting on 01223 890727 or email enquiries@theglobegroup.co.uk.
